New deadline: CMS extended the due date for all skilled nursing facility revalidations and for all “pending as of October 1” applications” until May 1, 2025.

• This replaces the original 90-day period that was required to submit the new Form CMS-855A SNF Disclosures Attachment 1 information (with exception of states impacted by the recent hurricanes) within 90 days of receiving notice from a respective Medicare Administrative Contractor (MAC) between October and December 2024.

How it happened: This positive development comes after AHCA/NCAL expressed strong concerns with the 90-day deadline to HHS and CMS in a letter last month.

• Mark your calendar for upcoming AHCA office hours to help you with your submissions.

The details: Specifically, the new CMS disclosable parties reporting submission timeline guidance states: 

Due Dates for All SNFs: Regardless of when the SNF received its notice of revalidation letter from its MAC (i.e., October, November, or December), the revalidation application due date for ALL SNFs – irrespective of the state in which they are located — is May 1, 2025. This May 1, 2025, due date also applies to ALL SNFs that – as explained in Section (I)(B) above – had a pending initial, revalidation, reactivation, or CHOW application as of October 1, 2024, and were requested to submit the SNF Attachment. The Attachment will not be due until May 1, 2025. The previous restriction of the May 1, 2025, date to SNFs in Florida, Georgia, South Carolina, North Carolina, and Tennessee no longer applies.

This is one of two updates posted by CMS over the past week to its sub regulatory guidance related to this revalidation process. It also contains new technical guidance, clarifications, and answers to FAQs to assist providers in submitting the required information, including clarification on: 

• The number of organizational charts that must be submitted (see Section (VI)(C)) 
• Clinical consulting services and policies/procedures (see new Section VI(G)))  
• Sections (III)(E)(i) and (ii) that both categories of bulleted parties must be reported.  

For members: AHCA/NCAL will continue to provide and update resources for members during this timeframe, including on the AHCA/NCAL website, as well as assisting members through the Member Provider Enrollment Revalidation Helpdesk.

• AHCA/NCAL will also host four Office Hours webinars on November 15, December 6, January 10, and January 31.
• Please contact 855Revalidation@ahca.org with any questions.